I believe you are conflating agencies.

The DEA (Drug Enforcement Administration, a branch of the Justice Department) often seizes assets. I am not familiar with the procedural requirement or operational controls of this agency.

The IRS’s only charge is the collection of taxes. Its only method of seizing assets is to go through a strict assessment and collection process; often taking a year or more (requiring multiple notices to the taxpayer).

Mr. McLellan had long known (or should have known) that his assets were at risk and why they were at risk.

If someone deposits 200,000 into their bank account and reports 100,000 of revenue on their income tax return there is a high likelihood of unreported income.

That they seized assets most likely indicates that he ignored the process (seizing the assessed tax was the only way to get him to respond). His explanation of this discrepancy was so weak that the Service decided that the case was worth litigating. The cost of litigating is certainly a multiple of the 107,000 seized.

PS: There are areas of the county that the IRS’s chances of winning court cases are very low (think Moonshine). Defense attorneys force civil court venues and choose trial by jury.